Welcome reader, here’s today’s Cyber Briefing Note.

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Coverage includes weekly CISO intelligence, deep-dive reports, and formal decision artifacts. Individual and organizational coverage available.

Board Risk Drift

The SEC dismissed its enforcement action against SolarWinds and its CISO with prejudice on November 20, 2025. At the same time, the SEC 2026 Examination Priorities reaffirm cybersecurity as a perennial examination focus, with continued focus on cybersecurity governance, controls, incident response readiness, and third party oversight.

The enforcement signal shifted. The examination standard did not.

Audit committees now face a different question. If individual CISOs are no longer the presumed enforcement target for disclosure failures, who inside the organization can demonstrate formal authority, documented reliance, and insurance coverage for the cybersecurity representations officers continue to sign?

In most enterprises, disclosure accountability was assigned to the CISO by implication rather than by board resolution, contractual authority, or explicit alignment with D&O coverage. That ambiguity was never stress tested while individual enforcement pressure appeared imminent.

The removal of that pressure does not eliminate exposure. It exposes a governance gap. Officers attested to cybersecurity statements without a documented chain showing who was authorized to bind those representations, what controls supported reliance, and where personal liability was intended to reside.

Accountability was assumed. Under examination, assumptions are not evidence.

Personal Judgment Coverage required